us-irs-announcements-irb-2000-18-pdf•Internal Revenue Bulletin 2000-18 (PDF rendition): IRS Announcements
Internal Revenue Bulletin 2000-18 (PDF rendition): IRS Announcements
us-irs-announcements-irb-2000-18-pdfInternal Revenue Bulletin 2000-18 (PDF rendition): IRS AnnouncementsGuidance
Preserve advance releases and the authoritative Internal Revenue Bulletin rendition; directory timestamps are file-publication metadata, not legal effective dates. HTML bulletins begin June 2003; earlier available issues require full PDF parsing. Whole bulletin rendition: numbered items are identified below; other legal material and publisher context remain included. This is not a new standalone advance release.
INCOME TAX Rev. Proc. 2000–14, page 960. Section 911(d)(4) waiver.Guidance is provided to individu- als who fail to meet the eligibility requirements of section 911(d)(1) of the Code because adverse conditions in a foreign country preclude the individual from meeting those require- ments. A current list of countries with the dates those coun- tries are subject to the section 911(d)(4) waiver is provided. Rev. Proc. 99–20 supplemented. ADMINISTRATIVE Announcement 2000–45, page 962. This announcement changes the date and location of the public hearing and provides notice of an extension of time for submitting comments with respect to proposed regula- tions (REG–208280–86, 2000–8 I.R.B. 654) relating to ex- clusions from gross income of foreign corporations under section 883 of the Code. The hearing is now scheduled for June 8, 2000. Internal Revenue bbuulllleettiinn Bulletin No. 2000–18 May 1, 2000 HIGHLIGHTS OF THIS ISSUE These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations. Department of the Treasury Internal Revenue Service Finding Lists begin on page ii. Index for January through April begins on page v. May 1, 20002000–18 I.R.B. The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for announcing offi- cial rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest. It is published weekly and may be obtained from the Superintendent of Documents on a subscription basis. Bulletin contents are consolidated semiannually into Cumulative Bulletins, which are sold on a single-copy basis. It is the policy of the Service to publish in the Bulletin all sub- stantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin. All published rulings apply retroactively unless other- wise indicated. Procedures relating solely to matters of in- ternal management are not published; however, statements of internal practices and procedures that affect the rights and duties of taxpayers are published. Revenue rulings represent the conclusions of the Service on the application of the law to the pivotal facts stated in the revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices, identifying details and information of a confidential nature are deleted to prevent unwarranted invasions of privacy and to comply with statutory requirements. Rulings and procedures reported in the Bulletin do not have the force and effect of Treasury Department Regulations, but they may be used as precedents. Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases. In applying pub- lished rulings and procedures, the effect of subsequent leg- islation, regulations, court decisions, rulings, and proce- dures must be considered, and Service personnel and oth- ers concerned are cautioned against reaching the same con- clusions in other cases unless the facts and circumstances are substantially the same. The Bulletin is divided into four parts as follows: Part I.—1986 Code. This part includes rulings and decisions based on provisions of the Internal Revenue Code of 1986. Part II.—Treaties and Tax Legislation. This part is divided into two subparts as follows: Subpart A, Tax Conventions, and Subpart B, Legislation and Related Committee Reports. Part III.—Administrative, Procedural, and Miscellaneous. To the extent practicable, pertinent cross references to these subjects are contained in the other Parts and Sub- parts. Also included in this part are Bank Secrecy Act Admin- istrative Rulings. Bank Secrecy Act Administrative Rulings are issued by the Department of the Treasury’s Office of the Assistant Secretary (Enforcement). Part IV.—Items of General Interest. This part includes notices of proposed rulemakings, disbar- ment and suspension lists, and announcements. The first Bulletin for each month includes a cumulative index for the matters published during the preceding months. These monthly indexes are cumulated on a semiannual basis, and are published in the first Bulletin of the succeeding semi- annual period, respectively. The IRS Mission Provide America’s taxpayers top quality service by help- ing them understand and meet their tax responsibilities and by applying the tax law with integrity and fairness to all. Introduction The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate. For sale by the Superintendent of Documents, U.S. Government Printing Office, Washington, DC 20402. Section 911.—Citizens or Residents of the United States Living Abroad 26 CFR 1.911–1: Partial exclusion for earned income from sources within a foreign country and foreign housing costs. Guidance is provided to individuals who fail to meet the eligibility requirements of section 911(d)(1) of the Internal Revenue Code because ad- verse conditions in a foreign country preclude the individual from meeting those requirements. A cur- rent list of countries with the dates those countries are subject to the section 911(d)(4) waiver is pro- vided. See Rev. Proc. 2000–14, page 960. 2000–18 I.R.B.959May 1, 2000 Part I. Rulings and Decisions Under the Internal Revenue Code of 1986 26 CFR 601.105: Examination of returns and claims for refund, credit, or abatement; determination of correct tax liability. (Also Part I, § 911, 1.911–1) Rev. Proc. 2000–14 SECTION 1. PURPOSE 01. This revenue procedure provides information to any individual who failed to meet the eligibility requirements of § 911(d)(1) of the Internal Revenue Code because adverse conditions in a foreign country precluded the individual from meeting those requirements for taxable year 1999. 02. The Internal Revenue Service has previously listed countries for which the el- igibility requirements of § 911(d)(1) of the Code are waived under § 911(d)(4) because of adverse conditions in those countries on and after the date stated. See Rev. Proc. 99–20, 1999–14 I.R.B. 7, Rev. Proc. 98–38, 1998–2 C.B. 28, and Rev. Proc. 97–51, 1997–2 C.B. 526. This revenue procedure lists countries added to the list in 1999, for which the eligibility requirements of § 911(d)(1) are waived. Rev. Proc. 99–20, Rev. Proc. 98–38, and Rev. Proc. 97–51 re- main in full force and effect. SEC. 2. BACKGROUND 01. Section 911(a) of the Code allows a “qualified individual,” as defined in § 911(d)(1), to exclude foreign earned in- come and housing cost amounts from gross income. Section 911(c)(3) of the Code allows a qualified individual to deduct housing cost amounts from gross income. 02. Section 911(d)(1) of the Code de- fines the term “qualified individual” as an individual whose tax home is in a foreign country and who is (A) a citizen of the United States and establishes to the satis- faction of the Secretary of the Treasury that the individual has been a bona fide resident of a foreign country or countries for an uninterrupted period that includes an entire taxable year, or (B) a citizen or resident of the United States who, during any period of 12 consecutive months, is present in a foreign country or countries during at least 330 full days. 03. Section 911(d)(4) of the Code pro- vides an exception to the eligibility re- quirements of § 911(d)(1). An individual will be treated as a qualified individual with respect to a period in which the indi- vidual was a bona fide resident of, or was present in, a foreign country if the indi- vidual left the country during a period for which the Secretary of the Treasury, after consultation with the Secretary of State, determines that individuals were required to leave because of war, civil unrest, or similar adverse conditions that precluded the normal conduct of business. An indi- vidual must establish that but for those conditions the individual could reason- ably have been expected to meet the eligi- bility requirements. 04. For 1999, the Secretary of the Trea- sury in consultation with the Secretary of State, has determined that war, civil unrest, or similar adverse conditions that precluded the normal conduct of business existed in the following countries beginning on or after the specified dates: Date of Departure CountryOn or After EritreaFebruary 12, 1999 EthiopiaFebruary 12, 1999 Serbia-MontenegroMarch 20, 1999 05. Accordingly, for purposes of § 911 of the Code, an individual who left one of the foregoing countries on or after the specified departure date shall be treated as a qualified individual with respect to the period during which that individual was present in, or was a bona fide resident of, such foreign country if the individual es- tablishes a reasonable expectation of meeting the requirements of § 911(d) but for those conditions. 06. To qualify for relief under § 911(d)(4) of the Code, an individual must have established residency or have been physically present in the foreign country on or prior to the date that the Secretary of the Treasury determines that individuals were required to leave the foreign coun- try. Individuals who establish residency or are first physically present in the for- eign country after the date that the Secre- tary prescribes, shall not be treated as qualified individuals under § 911(d)(4) of the Code pursuant to § 911(d)(4)(C). For example, individuals who are first physi- cally present in Eritrea after February 12, 1999, are not eligible to qualify for the exemption prescribed in § 911(d)(4) of the Code for taxable year 1999. 07. In order to assist those individuals who are filing prior year or amended tax returns, the Internal Revenue Service is republishing the countries listed for tax years 1996, 1997 and 1998, for which the eligibility requirements of § 911(d)(1) of the Code are waived under § 911(d)(4): May 1, 20009602000–18 I.R.B. Part III. Administrative, Procedural, and Miscellaneous Tax Year 1996 – Date of Departure CountryOn or AfterOn or Before Central African RepublicMay 21, 1996September 12, 1996 Tax Year 1997 – Date of Departure CountryOn or After AlbaniaMarch 12,1997 CambodiaJuly 9, 1997 Central African RepublicMarch 28, 1997 Democratic Republic of the CongoMay 3, 1997 Republic of the CongoJune 7, 1997 Sierra LeoneMay 28, 1997 TajikistanNovember 26, 1997 Tax Year 1998 – Date of Departure CountryOn or After AlbaniaAugust 14, 1998 Democratic Republic of the CongoAugust 5, 1998 EritreaJune 5, 1998 Guinea-BissauJune 10, 1998 IndonesiaMay 15, 1998 PakistanAugust 16, 1998 Sierra LeoneDecember 23, 1998 Serbia-Montenegro October 11, 1998 SEC. 3. INQUIRES A taxpayer who needs assistance on how to claim this exclusion, or on how to file an amended return, should contact a local IRS Office or, for a taxpayer resid- ing or traveling outside the United States, the nearest overseas IRS office. SEC. 4. EFFECT ON OTHER DOCUMENTS Rev. Proc. 99–20, 1999–14 I.R.B. 7, is supplemented. DRAFTING INFORMATION The principal author of this revenue procedure is Kate Y. Hwa of the Office of Associate Chief Counsel (International). For further information regarding this revenue procedure contact Ms. Hwa at (202) 622-3840 (not a toll-free call). 2000–18 I.R.B.961May 1, 2000 May 1, 20009622000–18 I.R.B. Exclusions From Gross Income of Foreign Corporations Announcement 2000–45 AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Proposed rule; change of date and location of the public hearing; and ex- tension of time for public comments. SUMMARY: This document changes the date and location of the public hearing and provides notice of an extension of time for submitting comments with re- spect to a notice of proposed rulemaking and notice of public hearing (REG– 208280–86, 2000–8 I.R.B. 654) relating to exclusions from gross income of for- eign corporations under section 883 of the Internal Revenue Code. DATES: Written and electronically gener- ated comments must be received by May 19, 2000. The public hearing is being held on Thursday, June 8, 2000, at 10 a.m. Requests to speak and outlines of topics to be discussed at the public hearing must be received by May 19, 2000. ADDRESSES: Send submissions to: CC:DOM:CORP:R (REG–208280–86), room 5226, Internal Revenue Service, POB 7604, Ben Franklin Station, Wash- ington, DC 20044. Submissions may be hand delivered between the hours of 8 a.m. and 5 p.m. to: CC:DOM:CORP:R (REG–208280–86), Courier’s Desk, In- ternal Revenue Service, 1111 Constitution Avenue, NW., Washington, DC. Alter- nately, taxpayers may submit comments electronically via the Internet by selecting the “Tax Regs” option on the IRS Home Page, or by submitting comments directly to the IRS internet site at http://www.irs.ustreas.gov/tax_regs/regsli st.html. The public hearing originally scheduled in the Internal Revenue Build- ing, room 2615, 1111 Constitution Av- enue, NW., Washington, DC, is changed to room 4718, in the Internal Revenue Building, 1111 Constitution Avenue, NW., Washington, DC, beginning at 10 a.m. FOR FURTHER INFORMATION CON- TACT: Concerning the regulations, Patri- cia A. Bray, (202) 622-3880; concerning submissions of comments, the hearing, and/or to be placed on the building access list to attend the hearing, contact Guy R. Traynor (202) 622-7180 (not toll-free numbers). SUPPLEMENTARY INFORMATION: A notice of proposed rulemaking and no- tice of public hearing appearing in the Federal Registeron Tuesday, February 8, 2000 (65 FR 6065), announced that a public hearing on proposed regulations relating to exclusions from gross income of foreign corporations under section 883, would be held on Thursday, April 27, 2000, beginning at 10 a.m. in room 2615 of the Internal Revenue Building, 1111 Constitution Avenue, NW., Washington, DC, and that requests to speak and out- lines of oral comments should be received by Wednesday, April 5, 2000. The date and location of the public hearing has changed, and the deadline for submitting written comments, requests to speak with outlines of topics to be dis- cussed at the hearing, has been extended. The hearing is scheduled for Thursday, June 8, 2000, beginning at 10 a.m. in room 4718 of the Internal Revenue Build- ing, 1111 Constitution Avenue, NW., Washington, DC. The date by which writ- ten comments on proposed rules, and re- quests to speak with outlines of topics to be discussed at the hearing must be deliv- ered or mailed, is hereby extended to May 19, 2000. The IRS will prepare an agenda show- ing the scheduling of speakers after the outlines are received from the persons tes- tifying and make copies available free of charge at the hearing, or in the Freedom of Information Reading Room (Room 1621), approximately one week prior to the hearing. Cynthia E. Grigsby, Chief, Regulations Unit, Assistant Chief Counsel (Corporate). (Filed by the Office of the Federal Register on March 28, 2000, 8:45 a.m., and published in the issue of the Federal Register for March 29, 2000, 65 F.R. 16554) Part IV. Items of General Interest 2000–18 I.R.B.iMay 1, 2000 Revenue rulings and revenue procedures (hereinafter referred to as “rulings”) that have an effect on previous rulings use the following defined terms to describe the effect: Amplified describes a situation where no change is being made in a prior pub- lished position, but the prior position is being extended to apply to a variation of the fact situation set forth therein. Thus, if an earlier ruling held that a principle applied to A, and the new ruling holds that the same principle also applies to B, the earlier ruling is amplified. (Compare with modified, below). Clarified is used in those instances where the language in a prior ruling is being made clear because the language has caused, or may cause, some confu- sion. It is not used where a position in a prior ruling is being changed. Distinguisheddescribes a situation where a ruling mentions a previously published ruling and points out an essen- tial difference between them. Modified is used where the substance of a previously published position is being changed. Thus, if a prior ruling held that a principle applied to A but not to B, and the new ruling holds that it ap- plies to both A and B, the prior ruling is modified because it corrects a published position. (Compare with amplified and clarified, above). Obsoleted describes a previously pub- lished ruling that is not considered deter- minative with respect to future transac- tions. This term is most commonly used in a ruling that lists previously published rulings that are obsoleted because of changes in law or regulations. A ruling may also be obsoleted because the sub- stance has been included in regulations subsequently adopted. Revoked describes situations where the position in the previously published rul- ing is not correct and the correct position is being stated in the new ruling. Superseded describes a situation where the new ruling does nothing more than restate the substance and situation of a previously published ruling (or rulings). Thus, the term is used to republish under the 1986 Code and regulations the same position published under the 1939 Code and regulations. The term is also used when it is desired to republish in a single ruling a series of situations, names, etc., that were previously published over a pe- riod of time in separate rulings. If the new ruling does more than restate the substance of a prior ruling, a combination of terms is used. For example, modified and superseded describes a situation where the substance of a previously pub- lished ruling is being changed in part and is continued without change in part and it is desired to restate the valid portion of the previously published ruling in a new ruling that is self contained. In this case the previously published ruling is first modified and then, as modified, is super- seded. Supplemented is used in situations in which a list, such as a list of the names of countries, is published in a ruling and that list is expanded by adding further names in subsequent rulings. After the original ruling has been supplemented several times, a new ruling may be pub- lished that includes the list in the original ruling and the additions, and supersedes all prior rulings in the series. Suspended is used in rare situations to show that the previous published rulings will not be applied pending some future action such as the issuance of new or amended regulations, the outcome of cases in litigation, or the outcome of a Service study. Abbreviations The following abbreviations in current use and for- merly used will appear in material published in the Bulletin. A—Individual. Acq.—Acquiescence. B—Individual. BE—Beneficiary. BK—Bank. B.T.A.—Board of Tax Appeals. C.—Individual. C.B.—Cumulative Bulletin. CFR—Code of Federal Regulations. CI—City. COOP—Cooperative. Ct.D.—Court Decision. CY—County. D—Decedent. DC—Dummy Corporation. DE—Donee. Del. Order—Delegation Order. DISC—Domestic International Sales Corporation. DR—Donor. E—Estate. EE—Employee. E.O.—Executive Order. ER—Employer. ERISA—Employee Retirement Income Security Act. EX—Executor. F—Fiduciary. FC—Foreign Country. FICA—Federal Insurance Contribution Act. FISC—Foreign International Sales Company. FPH—Foreign Personal Holding Company. F.R.—Federal Register. FUTA—Federal Unemployment Tax Act. FX—Foreign Corporation. G.C.M.—Chief Counsel’s Memorandum. GE—Grantee. GP—General Partner. GR—Grantor. IC—Insurance Company. I.R.B.—Internal Revenue Bulletin. LE—Lessee. LP—Limited Partner. LR—Lessor. M—Minor. Nonacq.—Nonacquiescence. O—Organization. P—Parent Corporation. PHC—Personal Holding Company. PO—Possession of the U.S. PR—Partner. PRS—Partnership. PTE—Prohibited Transaction Exemption. Pub. L.—Public Law. REIT—Real Estate Investment Trust. Rev. Proc.—Revenue Procedure. Rev. Rul.—Revenue Ruling. S—Subsidiary. S.P.R.—Statements of Procedral Rules. Stat.—Statutes at Large. T—Target Corporation. T.C.—Tax Court. T.D.—Treasury Decision. TFE—Transferee. TFR—Transferor. T.I.R.—Technical Information Release. TP—Taxpayer. TR—Trust. TT—Trustee. U.S.C.—United States Code. X—Corporation. Y—Corporation. Z—Corporation. Definition of Terms May 1, 2000ii2000–18 I.R.B. Numerical Finding List 1 Bulletins 2000–1 through 2000–17 Announcements: 2000–1, 2000–2 I.R.B. 294 2000–2, 2000–2 I.R.B. 295 2000–3, 2000–2 I.R.B. 296 2000–4, 2000–3 I.R.B. 317 2000–5, 2000–4 I.R.B. 427 2000–6, 2000–4 I.R.B. 428 2000–7, 2000–6 I.R.B. 586 2000–8, 2000–6 I.R.B. 586 2000–9, 2000–9 I.R.B. 733 2000–10, 2000–9 I.R.B. 733 2000–11, 2000–10 I.R.B. 739 2000–12, 2000–12 I.R.B. 835 2000–13, 2000–11 I.R.B. 771 2000–14, 2000–11 I.R.B. 772 2000–15, 2000–12 I.R.B. 837 2000–16, 2000–12 I.R.B. 837 2000–17, 2000–13 I.R.B. 846 2000–18, 2000–13 I.R.B. 846 2000–24, 2000–14 I.R.B. 855 2000–25, 2000–14 I.R.B. 855 2000–26, 2000–15 I.R.B. 876 2000–27, 2000–15 I.R.B. 876 2000–28, 2000–15 I.R.B. 876 2000–29, 2000–15 I.R.B. 877 2000–30, 2000–15 I.R.B. 877 2000–31, 2000–15 I.R.B. 877 2000–32, 2000–15 I.R.B. 879 2000–33, 2000–15 I.R.B. 878 2000–34, 2000–15 I.R.B. 879 2000–35, 2000–16 I.R.B. 922 2000–36, 2000–16 I.R.B. 947 2000–37, 2000–16 I.R.B. 947 2000–38, 2000–16 I.R.B. 948 2000–39, 2000–16 I.R.B. 948 2000–40, 2000–16 I.R.B. 948 2000–41, 2000–16 I.R.B. 949 2000–42, 2000–16 I.R.B. 949 2000–43, 2000–17 I.R.B. 957 2000–44, 2000–17 I.R.B. 958 Court Decisions: 2066, 2000–15 I.R.B. 867 2067, 2000–15 I.R.B. 863 Notices: 2000–1, 2000–2 I.R.B. 288 2000–2, 2000–9 I.R.B. 727 2000–3, 2000–4 I.R.B. 413 2000–4, 2000–3 I.R.B. 313 2000–5, 2000–3 I.R.B. 314 2000–6, 2000–3 I.R.B. 315 2000–7, 2000–4 I.R.B. 419 2000–8, 2000–4 I.R.B. 420 2000–9, 2000–5 I.R.B. 449 2000–10, 2000–5 I.R.B. 451 2000–11, 2000–6 I.R.B. 572 2000–12, 2000–9 I.R.B. 727 2000–13, 2000–9 I.R.B. 732 2000–14, 2000–10 I.R.B. 737 2000–15, 2000–12 I.R.B. 826 2000–16, 2000–12 I.R.B. 826 Notices—continued: 2000–17, 2000–12 I.R.B. 827 2000–18, 2000–13 I.R.B. 845 2000–19, 2000–13 I.R.B. 845 2000–20, 2000–14 I.R.B. 851 2000–22, 2000–16 I.R.B. 902 2000–23, 2000–17 I.R.B. 952 2000–24, 2000–17 I.R.B. 952 2000–25, 2000–17 I.R.B. 954 2000–26, 2000–17 I.R.B. 954 Proposed Regulations: REG–208280–86, 2000–8 I.R.B. 654 REG–209135–88, 2000–8 I.R.B. 681 REG–208254–90, 2000–6 I.R.B. 577 REG–209601–92, 2000–12 I.R.B. 829 REG–100276–97, 2000–8 I.R.B. 682 REG–101492–98, 2000–3 I.R.B. 326 REG–106012–98, 2000–2 I.R.B. 290 REG–109101–98, 2000–16 I.R.B. 903 REG–110311–98, 2000–11 I.R.B. 767 REG–103831–99, 2000–5 I.R.B. 452 REG–103882–99, 2000–8 I.R.B. 706 REG–105089–99, 2000–6 I.R.B. 580 REG–105279–99, 2000–8 I.R.B. 707 REG–105606–99, 2000–4 I.R.B. 421 REG–107872–99, 2000–16 I.R.B. 911 REG–111119–99, 2000–5 I.R.B. 455 REG–113572–99, 2000–7 I.R.B. 624 REG–116048–99, 2000–6 I.R.B. 584 REG–116567–99, 2000–5 I.R.B. 463 REG–116704–99, 2000–3 I.R.B. 325 REG–117162–99, 2000–15 I.R.B. 871 REG–100163–00, 2000–7 I.R.B. 633 REG–100291–00, 2000–16 I.R.B. 917 REG–103735–00, 2000–11 I.R.B. 770 REG–103736–00, 2000–11 I.R.B. 768 Railroad Retirement Quarterly Rate: 2000–9 I.R.B. 721 Revenue Procedures: 2000–1, 2000–1 I.R.B. 4 2000–2, 2000–1 I.R.B. 73 2000–3, 2000–1 I.R.B. 103 2000–4, 2000–1 I.R.B. 115 2000–5, 2000–1 I.R.B. 158 2000–6, 2000–1 I.R.B. 187 2000–7, 2000–1 I.R.B. 227 2000–8, 2000–1 I.R.B. 230 2000–9, 2000–2 I.R.B. 280 2000–10, 2000–2 I.R.B. 287 2000–11, 2000–3 I.R.B. 309 2000–12, 2000–4 I.R.B. 387 2000–13, 2000–6 I.R.B. 515 2000–15, 2000–5 I.R.B. 447 2000–16, 2000–6 I.R.B. 518 2000–17, 2000–11 I.R.B. 766 2000–18, 2000–9 I.R.B. 722 2000–19, 2000–12 I.R.B. 785 2000–20, 2000–6 I.R.B. 553 Revenue Rulings: 2000–1, 2000–2 I.R.B. 250 2000–2, 2000–3 I.R.B. 305 2000–3, 2000–3 I.R.B. 297 Revenue Rulings—continued: 2000–4, 2000–4 I.R.B. 331 2000–5, 2000–5 I.R.B. 436 2000–6, 2000–6 I.R.B. 512 2000–7, 2000–9 I.R.B. 712 2000–8, 2000–7 I.R.B. 617 2000–9, 2000–6 I.R.B. 497 2000–10, 2000–8 I.R.B. 643 2000–11, 2000–10 I.R.B. 734 2000–12, 2000–11 I.R.B. 744 2000–13, 2000–12 I.R.B. 774 2000–14, 2000–12 I.R.B. 779 2000–15, 2000–12 I.R.B. 774 2000–16, 2000–12 I.R.B. 780 2000–17, 2000–13 I.R.B. 842 2000–18, 2000–14 I.R.B. 847 2000–19, 2000–14 I.R.B. 849 2000–20, 2000–16 I.R.B. 880 2000–21, 2000–16 I.R.B. 881 2000–22, 2000–16 I.R.B. 880 Treasury Decisions: 8849, 2000–2 I.R.B. 245 8850, 2000–2 I.R.B. 265 8851, 2000–2 I.R.B. 275 8852, 2000–2 I.R.B.253 8853, 2000–4 I.R.B.377 8854, 2000–3 I.R.B.306 8855, 2000–4 I.R.B.374 8856, 2000–3 I.R.B.298 8857, 2000–4 I.R.B.365 8858, 2000–4 I.R.B.332 8859, 2000–5 I.R.B.429 8860, 2000–5 I.R.B.437 8861, 2000–5 I.R.B.441 8862, 2000–6 I.R.B.466 8863, 2000–6 I.R.B.488 8864, 2000–7 I.R.B.614 8865, 2000–7 I.R.B.589 8866, 2000–6 I.R.B.495 8867, 2000–7 I.R.B.620 8868, 2000–6 I.R.B.491 8869, 2000–6 I.R.B.498 8870, 2000–8 I.R.B.647 8871, 2000–8 I.R.B.641 8872, 2000–8 I.R.B.639 8873, 2000–9 I.R.B.713 8874, 2000–8 I.R.B.644 8875, 2000–11 I.R.B.761 8876, 2000–11 I.R.B.753 8877, 2000–11 I.R.B.747 8878, 2000–15 I.R.B.857 8879, 2000–16 I.R.B.882 1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 1999–27 through 1999–52 is in Internal Revenue Bulletin 2000–1, dated January 3, 2000. 2000–18 I.R.B.iiiMay 1, 2000 Finding List of Current Actions on Previously Published Items 1 Bulletins 2000–1 through 2000–17 Announcements: 99–40 Obsoleted by T.D. 8879, 2000–16 I.R.B. 882 99–50 Modified by Rev. Proc. 2000–20, 2000–6 I.R.B. 553 2000–18 Corrected by Announcement 2000–32, 2000–15 I.R.B. 878 Notices: 88–125 Obsoleted by T.D. 8870, 2000–8 I.R.B. 647 92–48 Obsoleted by Notice 2000–11, 2000–6 I.R.B. 572 97–19 Modified by Rev. Proc. 2000–1, 2000–1 I.R.B. 4 98–22 Obsoleted by T.D. 8870, 2000–8 I.R.B. 647 98–52 Modified by Notice 2000–3, 2000–4 I.R.B. 413 98–61 Modified and superseded by Rev. Proc. 2000–15, 2000–5 I.R.B. 447 99–8 Obsoleted by Rev. Proc. 2000–12, 2000–4 I.R.B. 387 2000–4 Corrected by Announcement 2000–9, 2000–9 I.R.B. 733 Proposed Regulations: REG–209601–92 Corrected by Announcement 2000–40, 2000–16 I.R.B. 948 REG–100276–97 Corrected by Announcement 2000–38, 2000–16 I.R.B. 948 REG–101492–98 Corrected by Announcement 2000–16, 2000–12 I.R.B. 837 REG–113572–99 Corrected by Announcement 2000–41, 2000–16 I.R.B. 949 REG–103736–00 Corrected by Announcement 2000–44, 2000–17 I.R.B. 958 Revenue Procedures: 80–18 Modified by Rev. Proc. 2000–13, 2000–6 I.R.B. 515 Revenue Procedures—Continued: 89–9 Superseded by Rev. Proc. 2000–20, 2000–6 I.R.B. 553 89–13 Superseded by Rev. Proc. 2000–20, 2000–6 I.R.B. 553 90–21 Superseded by Rev. Proc. 2000–20, 2000–6 I.R.B. 553 91–66 Superseded by Rev. Proc. 2000–20, 2000–6 I.R.B. 553 92–13 Modified, amplified, and superseded by Rev. Proc. 2000–11, 2000–3 I.R.B. 309 92–13A Modified, amplified, and superseded by Rev. Proc. 2000–11, 2000–3 I.R.B. 309 92–41 Superseded by Rev. Proc. 2000–20, 2000–6 I.R.B. 553 93–9 Superseded by Rev. Proc. 2000–20, 2000–6 I.R.B. 553 93–10 Superseded by Rev. Proc. 2000–20, 2000–6 I.R.B. 553 94–12 Modified, amplified, and superseded by Rev. Proc. 2000–11, 2000–3 I.R.B. 309 95–42 Superseded by Rev. Proc. 2000–20, 2000–6 I.R.B. 553 96–13 Modified by Rev. Proc. 2000–1, 2000–1 I.R.B. 4 98–22 Modified and superseded by Rev. Proc. 2000–16, 2000–6 I.R.B. 518 98–27 Superseded by Rev. Proc. 2000–12, 2000–4 I.R.B. 387 98–64 Superseded by Rev. Proc. 2000–9, 2000–2 I.R.B. 280 98–65 Superseded by Rev. Proc. 2000–19, 2000–12 I.R.B. 785 99–1 Superseded by Rev. Proc. 2000–1, 2000–1 I.R.B. 4 99–2 Superseded by Rev. Proc. 2000–2, 2000–1 I.R.B. 73 99–3 Superseded by Rev. Proc. 2000–3, 2000–1 I.R.B. 103 99–4 Superseded by Rev. Proc. 2000–4, 2000–1 I.R.B. 115 Revenue Procedures—Continued: 99–5 Superseded by Rev. Proc. 2000–5, 2000–1 I.R.B. 158 99–6 Superseded by Rev. Proc. 2000–6, 2000–1 I.R.B. 187 99–7 Superseded by Rev. Proc. 2000–7, 2000–1 I.R.B. 227 99–8 Superseded by Rev. Proc. 2000–8, 2000–1 I.R.B. 230 99–13 Modified and superseded by Rev. Proc. 2000–16, 2000–6 I.R.B. 518 99–31 Modified and superseded by Rev. Proc. 2000–16, 2000–6 I.R.B. 518 99–49 Modified and amplified by Rev. Rul. 2000–4, 2000–4 I.R.B. 331 Rev. Rul. 2000–7, 2000–9 I.R.B. 712 Notice 2000–4, 2000–3 I.R.B. 313 99–51 Superseded by Rev. Proc. 2000–3, 2000–1 I.R.B. 103 2000–6 Modified by Rev. Proc. 2000–20, 2000–6 I.R.B. 553 2000–8 Modified by Rev. Proc. 2000–16, 2000–6 I.R.B. 518 Rev. Proc. 2000–20, 2000–6 I.R.B. 553 2000–16 Corrected by Announcement 2000–17, 2000–13 I.R.B. 846 Revenue Rulings: 57–259 Obsoleted by T.D. 8879, 2000–16 I.R.B. 882 57–499 Obsoleted by T.D. 8879, 2000–16 I.R.B. 882 73–292 Obsoleted by T.D. 8879, 2000–16 I.R.B. 882 78–218 Obsoleted by T.D. 8879, 2000–16 I.R.B. 882 86–62 Obsoleted by T.D. 8879, 2000–16 I.R.B. 882 88–36 Modified by Rev. Rul. 2000–6, 2000–6 I.R.B. 512 89–89 Obsoleted by Rev. Rul. 2000–2, 2000–3 I.R.B. 305 1 A cumulative list of current actions on previously published items in Internal Revenue Bulletins 1999–27 through 1999–52 is in Internal Revenue Bulletin 2000–1, dated January 3, 2000. May 1, 2000iv2000–18 I.R.B. Revenue Rulings—continued: 92–19 Supplemented by Rev. Rul. 2000–17, 2000–13 I.R.B. 842 98–30 Amplified and superseded by Rev. Rul. 2000–8, 2000–7 I.R.B. 617 Treasury Decisions: 8734 Modified by T.D. 8856, 2000–3 I.R.B. 298 8804 Modified by T.D. 8856, 2000–3 I.R.B. 298 8845 Corrected by Announcement 2000–6, 2000–4 I.R.B. 428 8846 Corrected by Announcement 2000–3, 2000–2 I.R.B. 296 8847 Corrected by Announcement 2000–13, 2000–11 I.R.B. 771 8849 Corrected by Announcement 2000–28, 2000–15 I.R.B. 876 8852 Corrected by Announcement 2000–18, 2000–13 I.R.B. 846 8853 Corrected by Announcement 2000–33, 2000–15 I.R.B. 878 8856 Corrected by Announcement 2000–31, 2000–15 I.R.B. 877 8859 Corrected by Announcement 2000–27, 2000–15 I.R.B. 876 8864 Corrected by Announcement 2000–26, 2000–15 I.R.B. 876 8865 Corrected by Announcement 2000–37, 2000–16 I.R.B. 947 8867 Corrected by Announcement 2000–30, 2000–15 I.R.B. 877 8869 Corrected by Announcement 2000–36, 2000–16 I.R.B. 947 8870 Corrected by Announcement 2000–34, 2000–15 I.R.B. 879 8874 Corrected by Announcement 2000–29, 2000–15 I.R.B. 877 Index Internal Revenue Bulletins 2000–1 Through 2000–17 The abbreviation and number in paren- thesis following the index entry refer to the specific item; numbers in roman and italic type following the parenthesis refer to the Internal Revenue Bulletin in which the item may be found and the page number on which it appears. Key to Abbreviations: AnnAnnouncement CDCourt Decision DODelegation Order EOExecutive Order PLPublic Law PTEProhibited Transaction Exemption RPRevenue Procedure RRRevenue Ruling SPRStatement of Procedural Rules TCTax Convention TDTreasury Decision TDOTreasury Department Order EMPLOYEE PLANS Areas in which advance letter rulings and determination letters will not be issued from Associate Chief Counsel, Domestic (RP 3) 1, 103 Areas in which advance letter rulings and determination letters will not be issued from Associate Chief Counsel, International (RP 7) 1, 227 Cafeteria plans, treatment of (TD 8878) 15, 857; (REG-117162–99) 15, 871 Cash or deferred arrangements: Elective deferrals (RR 8) 7, 617 Nondiscrimination (Notice 3) 4, 413 Determination letters, issuing procedures (RP 6) 1, 187 Eligible rollover distributions, safe har- bor explanations (Notice 11) 6, 572 EPCRS, closing agreements (RP 16) 6,518; correction (Ann 17) 13,846 Full funding limitations, weighted aver- age interest rate for: January (Notice 8) 4, 420 February (Notice 2) 9,727 March (Notice 18) 13, 845 April (Notice 25) 17, 954 Letter rulings, determination letters and information letters issued by Associate Chief Counsel (RP 1) 1, 4 Letter rulings, information letters, etc. (RP 4) 1, 115 Master and prototype plans, unified pro- cedures (RP 20) 6, 553 Minimum funding standards: Amortization bases (RR 20) 16, 880 Waiver of the 100 percent tax (RP 17) 11, 766 Mortality tables (Ann 7) 6, 586 New comparability plans, nondiscrimina- tion (Notice 14) 10, 737 New technologies in retirement plans, distribution notices and consents (TD 8873) 9, 713 Proposed Regulations: 26 CFR 1.125–1, amended; 1.125–2, amended; 1.125–4, amended; tax treatment of cafeteria plans (REG–117162–99) 15, 871 26 CFR 1.411(d)–4, amended; special rules regarding optional forms of benefit under qualified retirement plans (REG–109101–98) 16, 903 Qualified retirement plans: Optional forms of benefit (REG–109101–98) 16, 903 Remedial amendment period (TD 8871) 8, 641 Regulations: 26 CFR 1.125–4, added; 1.125–4T, amended; tax treatment of cafeteria plans (TD 8878) 15, 857 26 CFR 1.401(b)–1T, removed; reme- dial amendment period (TD 8871) 8, 641 26 CFR 1.402(f)–1, amended; 1.411(a)–11, amended; new tech- nologies in retirement plans (TD 8873) 9,713 Reporting requirements, section 457 plans (Ann 1) 2, 294 Technical advice to district directors and chiefs, appeals offices, from Associate Chief Counsel (RP 2) 1, 73 Technical advice to IRS employees (RP 5) 1, 158 User fees, request for letter rulings (RP 8) 1, 230 EMPLOYMENT TAX Electronically filed information returns, due dates (REG–105279–99) 8, 707 EPCRS, closing agreements (RP 16) 6, 518; correction (Ann 17) 13, 846 Information reporting: Election workers (RR 6) 6,512 New technologies in retirement plans, distribution notices and consents (TD 8873) 9, 713 Proposed Regulations: 26 CFR 31.3402(q)–1, revised; 31.6053–3, revised; 31.6071(a)–1, revised; extension of due date for electronically filed information returns (REG–105279–99) 8, 707 Railroad retirement, quarterly rate beginning January 1, 2000, 9, 721 Regulations: 26 CFR 35.3405–1, redesignated as 35.3405–1T, revised; 35.3405–1, added; new technologies in retire- ment plans (TD 8873) 9, 713 ESTATE TAX Guaranteed annuity interests and unitrust interests (REG–100291–00) 16, 917 Marital / charitable deduction, valuation of property; administration expenses (Ann 3) 2, 296 Proposed Regulations: 26 CFR 1.170A–6, amended; 20.2055–2, amended; 25.2522(c)–3, amended; guaranteed annuity inter- ests and unitrust interests (REG–100291–00) 16, 917 QTIP elections, individual retirement accounts and testamentary trusts (RR 2) 3, 305 Valuation tables (Ann 25) 14, 855 EXCISE TAX Gasoline and diesel fuel dye injection systems, partial withdrawal of REG–209735–95 (Ann 42) 16, 949 Imported substances, tax on (Ann 43) 17, 957 Kerosene tax; aviation fuel tax; taxable fuel measurement and reporting; tax on heavy trucks and trailers; highway use tax (TD 8879) 16,882 Minimum funding standards, waiver of (RP 17) 11, 766 Prepaid telephone cards (TD 8855) 4, 374 Regulations: 26 CFR 40.6011(a)–1, amended; 2000–18 I.R.B.vMay 1, 2000 EMPLOYEE PLANS— cont. EMPLOYMENT TAX— cont. 41.0–1, revised; 41.02–2, –3, removed; 41.4481–1T, 1.4481–1, –2, amended; 41.4481–1T, removed; 41.4482(a)–1, amended; 41.4482(b)–1, amended; 41.4482(b)–1T, removed; 41.4482(c)–1, amended; 41.4483–1, revised; 41.4483–2, –3, amended; 41.4483–5, removed; 41.4484–1, removed; 41.6001–1, –2, amended; 41–6011(a)–1, revised; 41.6071(a)–1, amended; 41.6081(a)–1, removed; 41.6091–1, revised; 41–6101–1, revised; 41.6109–1, revised; 41.6151(a)–1, revised; 41.6161(a)(1)–1, removed; 41.6302(b)–1, removed; 41.7805–1, removed; Part 47, removed; 48.0–2, amended; 48.4041–21, amended; 48.4052–1, added; 48.4081–1, amended; 48.4081–1T, removed; 48.4081–2, –3, –6, –7, –8, amended; 48.4081–9, removed; 48.4082–1, amended; 48.4082–2, –3, revised; 48.4082–4, –5, amended; 48.4082–6, –7, added; 48.4082–6T, –7T, –8T, –9T, –10T, removed; 48.4083–1, amended; 48.4091–3T, redesignated as 48.4091–3, amend- ed; 48.4101–3T, removed; 48.4101–1, –2, amended; 48.4102–2T, removed; 48.4221–1, amended; 48.4222(b)–1, amended; 48.6416(b)(2)–1, –2, amended; 48.6420–7, removed; 48.6420(c)–2, removed; 48.6421–2, amended; 48.6427–8, –9, amended; 48.6427–10T, –11T, removed; 48.6427–10, –11, added; 48.6715–1, amended; 145.4051–1, amended; 145.4052–1, amended; kerosene tax; aviation fuel tax; taxable fuel mea- surement and reporting; tax on heavy trucks and trailers; highway use tax (TD 8879) 16, 882 26 CFR 49.4251–4, added; 602.101, amended; prepaid telephone cards (TD 8855) 4, 374 Return filing and deposits (Ann 5) 4, 427 Areas in which advance letter rulings and determination letters will not be issued from Associate Chief Counsel, Domestic (RP 3) 1, 103 Charitable split dollar insurance, report- ing requirements (Notice 24) 17, 952 Information letters available for public inspection (Ann 2) 2, 295 Letter rulings, information letters, etc. (RP 4) 1, 115 List of organizations classified as private foundations (Ann 8) 6, 586 Private foundation disclosure rules (TD 8861) 5, 441 Proposed Regulations: 26 CFR 1.170A–9(e)(6)(i), amended; 1.509(a)–3(f)(1), amended; 1.512(a)–1(e), amended; 1.513–4, withdrawn; 1.513–4, added; taxation of tax-exempt organizations’ income from corporate sponsorship (REG–209601–92) 12, 829; correc- tion (Ann 40) 16, 948 Regulations: 26 CFR 1.513–7, added; travel and tour activities of tax-exempt organi- zations (TD 8874) 8, 644; correction (Ann 29) 15, 877 26 CFR 301.6104(d)–1, removed; 301.6104(d)–2, redesignated as 301.6104(d)–0, revised; 301.6104(d)–3, redesignated as 301.6104(d)–1, amended; 301.6104(d)–4, redesignated as 301.6104(d)–2, amended; 301.6104(d)–5, redesignated as 301.6104(d)–3, amended; private foundation disclosure rules (TD 8861) 5, 441 Revocations: (Ann 15) 12, 837 (Ann 39) 16, 948 Sponsorship payments, taxation of (REG–209601–92) 12, 829; correction (Ann 40) 16, 948 Technical advice to district directors and chiefs, appeals offices, from Associate Chief Counsel (RP 2) 1, 73 Technical advice to IRS employees (RP 5) 1, 158 Travel tours, taxation of (TD 8874) 8, 644; correction (Ann 29) 15, 877 User fees, request for letter rulings (RP 8) 1, 230 Guaranteed annuity interests and unitrust interests (REG–100291–00) 16, 917 Proposed Regulations: 26 CFR 1.170A-6, amended; 20.2055–2, amended; 25.2522(c)–3, amended; guaranteed annuity inter- ests and unitrust interests (REG–100291–00) 16, 917 INCOME TAX Accounting period change, automatic consent (RP 11) 3, 309 Acquisitions, recognition of gain on dis- tributions (Ann 10) 9, 733 Adequate disclosure of gifts (Ann 6) 4, 428 Advance pricing agreements (Ann 35) 16, 922 Allocation of partnership debt, nonre- course liabilities (REG–103831–99) 5, 452 Amortization of intangible property (TD 8865) 7, 589; correction (Ann 37) 16, 947 Appeals, test of arbitration procedure (Ann 4) 3, 317 Areas in which advance letter rulings and determination letters will not be issued from Associate Chief Counsel, International (RP 7) 1, 227 Asset acquisitions, allocation of purchase price (TD 8858) 4, 332 Automobile owners and lessees (RP 18) 9, 722 Barter exchanges, information reporting (Notice 6) 3, 315 Business expenses: ISO 9000 costs (RR 4) 4, 331 Substantiation (TD 8864) 7,614; cor- rection (Ann 26) 15,876 Traveling expenses, per diem allowances (RP 9) 2, 280 Canadian banking legislation, repeal, deferral of termination (Notice 7) 4, 419 Closely-held real estate investment trust, estimated tax payments, penalty relief (Notice 5) 3, 314 Contribution in aid of construction, defi- nition (REG–106012–98) 2, 290 Credits: Low-income housing credit: Compliance monitoring (TD 8859) May 1, 2000vi2000–18 I.R.B. EXCISE TAX—cont.EXEMPT ORGANIZATIONS GIFT TAX 5, 429; correction (Ann 27) 15, 876 Resident population estimates (Notice 13) 9, 732 Satisfactory bond; “bond factor” amounts for the period January through March 2000 (RR 22) 16, 880 Puerto Rico and possession tax credit, termination of (TD 8868) 6, 491 Research credit, controlled group (REG–105606–99) 4, 421 Debt instrument (RR 12) 11, 744 Depletion, treatment of delay rental (REG–103882–99) 8, 706 Depreciation: MACRS property, involuntary conver- sion or like-kind exchange (Notice 4) 3, 313; correction (Ann 9) 9, 733 Determination of underwriting income, non-life insurance companies (TD 8857) 4, 365 Disclosure of return information, Census of Agriculture (TD 8854) 3,306; (REG–116704–99) 3, 325 Electronically filed information returns, due dates of (REG–105279–99) 8, 707 Equity options with flexible terms, special rules and definitions (TD 8866) 6, 495 Estimated taxes: Closely-held real estate investment trust, penalty relief (Notice 5) 3, 314 Date deemed paid (CD 2066) 15, 867 Filing requirements: Northeastern taxpayers, due dates (Notice 17) 12, 827 Financial asset securitization investment trusts, general (REG–100276–97; REG–122450–98) 8, 682; correction (Ann 38) 16, 948 Foreign corporations: Exclusion of shipping income (REG–208280–86) 8, 654 Information reporting (TD 8850) 3, 265 Stock transfer rules: General provisions (TD 8862) 6, 466 Nonrecognition (TD 8863) 6, 488; (REG–116048–99) 6, 584 Foreign currency: Gains and losses, qualified business units (Notice 20) 14, 851 Hyperinflation; definition (REG–116567–99) 5, 463; (TD 8860) 5, 437 Foreign partnerships: Information reporting (TD 8850) 3, 265 U.S. persons with reportable event, reporting requirement (TD 8851) 2, 275 Foreign persons, distributions to (Ann 24) 14, 855 Form SS-4, interim waiver of signature (Notice 19) 13, 845 Fringe benefits: Aircraft valuation (RR 13) 12, 774 Qualified transportation (REG–113572–99) 7,624; correc- tion (Ann 41) 61,949 Guaranteed annuity interests and unitrust interests, definition of (REG–100291– 00) 16, 917 Guidance priority list (Notice 10) 5, 451 Information letters available for public inspection (Ann 2) 2, 295 Information reporting: Barter exchange (Notice 6) 3, 315 Discharges of indebtedness, penalties for (Notice 22) 16, 902 Foreign partnerships and foreign cor- porations (TD 8850) 3, 265 Innocent spouse, equitable relief (RP 15) 5, 447 Installment agreements, limitation of fail- ure to pay penalty (REG–105279–99) 8, 707 Installment sales (Notice 26) 17, 954 Insurance companies: Differential earnings rate, tentative (Notice 16) 12, 826 Prevailing state assumed interest rates (RR 17) 13, 842 Interest: Investment: Federal short-term, mid-term, and long-term rates for: January 2000 (RR 1) 2, 250 February 2000 (RR 9) 6,497 March 2000 (RR 11) 10, 734 April 2000 (RR 19) 14, 849 Rates: Underpayment and overpayment, quarter beginning April 1, 2000 (RR 16) 12, 780 Inventory: LIFO: Price indexes, department stores: November 1999 (RR 3) 3, 297 December 1999 (RR 10) 8,643 January 2000 (RR 14) 12,779 February 2000 (RR 21) 16, 881 Letter rulings, determination letters and information letters issued by Associate Chief Counsel (RP 1) 1, 4 Major disaster and emergency areas, losses (RR 15 ) 12, 774 Nonconventional source fuel credit, inflation adjustment factor and refer- ence price (Notice 23) 17, 952 Nonqualified preferred stock, exchanges and distributions (REG–105089–99) 6, 580 Partnerships: Adjustments following sales (Ann 13) 11, 771 Allocation of basis adjustments among partnership assets (REG–107872–99) 16, 911 Allocation of nonrecourse liabilities (REG–103831–99) 5,452 Amortization of intangible property (REG–100163–00) 7, 633 Basis adjustments, residual method, valuation of partnership assets including goodwill (REG–107872–99) 16, 911 Mergers and divisions (REG–111119–99) 5, 455 Qualified replacement property, trans- fer to (RR 18) 14, 847 Passive foreign investment companies: Marketable stock (TD 8867) 7, 620; correction (Ann 30) 15,877 Qualified electing fund (TD 8870) 8, 647; correction (Ann 34) 15, 879 Pre-filing agreement pilot program (Notice 12) 9, 727 Presidentially declared disaster and com- bat zone, relief (REG–101492–98) 3, 326; correction (Ann 16) 12, 837 Private foundations: Disclosure rules (TD 8861) 5, 442 Organizations now classified as (Ann 8) 6,586 Proposed Regulations: 26 CFR 1.41–0, amended; 1.41–8, revised; credit for increasing research activities (REG–105606–99) 4, 421 26 CFR 1.118–2, added; contribution 2000–18 I.R.B.viiMay 1, 2000 INCOME TAX—cont.INCOME TAX—cont.INCOME TAX—cont. in aid of construction, definition (REG–106012–98) 2, 290 26 CFR 1.132–0, amended; 1.132–9, added; qualified transportation fringe benefits (REG–113572–99) 7, 624; correction (Ann 41) 16, 949 26 CFR 1.170A–6, amended; 20.2055–2, amended; 25.2522(c)–3, amended; lifetime charitable lead trusts (REG–100291–00) 16, 917 26 CFR 1.197–2, amended; amortiza- tion of intangible property (REG–100163–00) 7, 633 26 CFR 1.337(d)–5T, added, 1.852–12, added; 1.857–11, added; certain asset transfers to regulated investment companies and real estate investment trusts (REG–209135–88) 8, 681 26 CFR 1.354–1, amended; 1.355–1, amended; 1.356–7, added; 1.1036–1, amended; treatment of nonqualified perferred stock and other preferred stock in certain exchanges and distributions (REG–105089–99) 6, 580 26 CFR 1.367(b)–3, amended; stock transfer rules (REG–116048–99) 6, 584 26 CFR 1.612–3, amended; depletion, treatment of delay rental (REG–103882–99) 8, 706 26 CFR 1.708–1, amended; 1.743–1, amended; treatment of partnership mergers and divisions (REG–111119–99) 5, 455 26 CFR 1.752–3, amended; 1.752–5, revised; allocation of nonrecourse liabilities by a partnership (REG–103831–99) 5, 452 26 CFR 1.755–2, added; 1.755–2T, removed; allocation of basis adjust- ments among partnership assets (REG–107872–99) 16, 911 26 CFR 1.860E–1, amended; 1.860H–0, –1, –2, –3, –4, –5, –6, added; 1.860I–1, –2, added; 1.860J–1, added; 1.860L–1, –2, –3, –4, added; 1.861–9T, amended; 1.861–10T, amended; financial asset securitization investment trusts; real estate mortgage investment conduits (REG–100276–97; REG–122450–98) 8, 682; correction (Ann 38) 16,948 26 CFR 1.861–4, amended; source of compensation for labor or personal services (REG–208254–90) 6, 577 26 CFR 1.883–0, added; 1.883–1, revised; 1.883–2, –3, –4, –5, added; exclusions from gross income of foreign corporations (REG–208280–86) 8, 654 26 CFR 1.988–1, revised; hyperinfla- tionary currencies, definition (REG–116567–99) 5, 463 26 CFR 1.6011–4, added; tax shelter disclosure statements (REG–103735–00) 11, 770 26 CFR 1.6041–2, revised; 1.6041–6, revised; 1.6042–2, revised; 1.6043–2, revised; 1.6044–2, revised; 1.6045–1, added; 1.6045–2, revised; 1.6045–4, revised; 1.6047–1, revised; 1.6049–4, revised; 1.6049–7, revised; 1.6050A–1, revised; 1.6050D–1, revised; 1.6050E–1, revised; 1.6050H–2, revised; 1.6050J–1T, revised; 1.6050P–1, revised; 1.6052–1, revised; 301.6651–1, amended; extension of due date for electronically filed information returns; limitation of failure to pay penalty for individuals during peri- od of installment agreement (REG–105279–99) 8, 707 26 CFR 301.6103(j)(5)–1, added; dis- closure of return information; Census of Agriculture (REG–116704–99) 3, 325 26 CFR 301.6111–2, added; corporate tax shelter registration (REG–110311–98) 11, 767 26 CFR 301.6112–1, amended; requirements to maintain list of investors in potentially abusive tax shelters (REG–103736–00) 11, 768; correction (Ann 44) 17, 958 26 CFR 301.7508–1, added; 301.7508A–1, added; relief for ser- vice in combat zone and for Presidentially declared disaster (REG–101492–98) 3, 326; correc- tion (Ann 16) 12, 837 Publications: 515, changes to Tables 1 and 2 (Ann 11) 10, 739 1167, substitute forms, general requirements (RP 19) 12, 785 1212, supplemental information (Ann 14) 11, 772 Qualified Zone Academy Bonds (RP 10) 2, 287 Real estate investment trusts, asset trans- fers to (TD 8872) 8, 639; (REG–209135–88) 8, 681 Real estate mortgage investment con- duits, safe harbor (REG–100276–97; REG–122450–98) 8, 682; correction (Ann 38) 16,948 Recharacterizing financing arrangements, fast-pay stock (TD 8853) 4, 377; cor- rection (Ann 33) 15, 878 Regulated investment companies, asset transfers to (TD 8872) 8, 639; (REG–209135–88) 8, 681 Regulations: 26 CFR 1.42–5, –6, amended; 1.42 –11, –12, –13, amended; 1.42–17, added; compliance monitoring and miscellaneous issues relating to the low-income housing credit (TD 8859) 5, 429 26 CFR 1.62–2, amended; 1.62–2T, removed; 1.274–5, added; 1.274–5T, amended; substantiation of business expenses (TD 8864) 7, 614; correction (Ann 26) 15, 876 26 CFR 1.162–11, amended; 1.167(a)–3, amended; 1.167(a)–6, amended; 1.167(a)–14, added; 1.197–0, added; 1.197–2, added; amortization of goodwill and certain other intangibles (TD 8865) 7, 589; correction (Ann 37) 16, 947 26 CFR 1.337(d)–5, added, certain asset transfers to regulated invest- ment companies and real estate investment trusts (TD 8872) 8, 639 26 CFR 1.338–0, –1, –2, –3, removed; 1.338–4, redesignated as 1.338–8; 1.338–5, redesignated as 1.338–9; 1.338–4T, –5T, –6T, –7T, –10T, added; 1.338(b)–1, added; 1.338(b)–2T, –3T, removed; 1.338(h)(10)–1, removed; 1.338(i)–1, removed; 1.338(i)–1T, added; 1.1060–1T, revised; purchase price allocations in deemed and actual asset acquisitions (TD 8858) 4, 332 26 CFR 1.367(a)–3, amended; May 1, 2000viii2000–18 I.R.B. INCOME TAX—cont.INCOME TAX—cont.INCOME TAX—cont. 1.367(b)–0, added; 1.367(b)–1, –2, revised; 1.367(b)–3, added; 1.367(b)–4, revised; 1.367(b)–5, –6, added; 1.367(b)–7, –8, –9, removed; 1.381(b)–1, amended; 7.367(b)–1, –2, –3, –4, –5, –6, –7, –8, –9, –10, –11, removed; 7.367(b)–12, amend- ed; 7.367(b)–13, removed; stock transfers rules (TD 8862) 6, 466 26 CFR 1.367(b)–3T, added; stock transfer rules, (TD 8863) 6, 488 26 CFR 1.367(e)–1, –2, corrected; treatment of distributions to foreign persons (Ann 24) 14, 855 26 CFR 1.401(b)–1, amended; 1.401(b)–1T, removed; remedial amendment period (TD 8871) 8, 641 26 CFR 1.513–7, added; travel and tour activities of tax-exempt organi- zations (TD 8874) 8, 644 26 CFR 1.663(a)–1, amended; 1.663(c)–1, amended; 1.663(c)–2, revised; 1.663(c)–3, amended; 1.663(c)–4, redesignated as 1.663(c)–5, amended; 1.663(c)–4, added; 1.663(c)–6, added; separate shares rule applicable to estates (TD 8849) 2, 245; correction (Ann 28) 15,876 26 CFR 1.664–2, corrected; use of actuarial tables in valuing annuities, interests for life or term of years, and remainder or reversionary inter- ests (Ann 25) 14, 855 26 CFR 1.743–1, 1.754–1, 1.755–1, corrected; adjustments following sales of partnership interests (Ann 13) 11, 771 26 CFR 1.871–14, revised; 1.1441–1, –4, –5, –6, –8, –9, revised; 1.1443–1, revised; 1.6042–3, revised; 1.6045–1, revised; 1.6049–5, revised; withholding of tax on certain U.S. source income paid to foreign persons; delay of effective date (TD 8856) 3, 298; correction (Ann 31) 15, 877 26 CFR 1.936–11T, removed; 1.936–11, added; termination of Puerto Rico and possession tax credit (TD 8868) 6, 491 26 CFR 1.988–0, amended; 1.988–2, amended; treatment of income and expenses from certain hyperinfla- tionary currencies; nonperiodic pay- ments (TD 8860) 5, 437 26 CFR 1.1092(c)–1, added; equity options with flexible terms (TD 8866) 6, 495 26 CFR 1.1291–1T, redesignated as 1.1291–1, revised; 1.1293–1T, redesignated as 1.1293–1, revised; 1.1295–0, amended; 1.1295–1T, redesignated as 1.1295–1, amended; 1.1295–3T, redesignated as 1.1295–3, amended; general rules for making and maintaining quali- fied electing fund elections (TD 8870) 8, 647; correction (Ann 34) 15,879 26 CFR 1.1296(e)–1, added; passive foreign investment companies, mar- ketable stock (TD 8867) 7, 620; cor- rection (Ann 30) 15,877 26 CFR 1.1361–0, –1; amended; 1.1361–2, –3, –4, –5, –6, added; 1.1362–0, amended; 1.1362–2, amended; 1.1362–8, added; 1.1368–0, amended; 1.1368–2, amended; 1.1374–8, amended; 301.6109–1, amended; subchapter S subsidiaries (TD 8869) 6, 498; cor- rection (Ann 36) 16,947 26 CFR 1.1366–0, –1, added; 1.1366–2, revised; 1.1366–3, –4, –5, added; 1.1367–0, –1, amended; 1.1367–3, revised; 1.1368–0, –1, –2, –3, amended; 1.1368–4, revised; passthrough of items of an S corpo- ration to its shareholders (TD 8852) 2, 253; correction (Ann 18) 13,846; correction (Ann 32) 15,878 26 CFR 1.1441–10, added; 1.7701(1)–0, added; 1.7701(1)–3, added; 602.101(b), amended; recharacteriz- ing financing arrangements involving fast–pay stock (TD 8853) 4, 377; cor- rection (Ann 33) 15,878 26 CFR 1.6011–4T, added; tax shelter disclosure statements (TD 8877) 11, 747 26 CFR 1.6038–3, added; 1.6038–2, amended; 1.6038B–1, amended; 1.6038B–2, amended; information reporting with respect to certain for- eign partnerships and certain foreign corporations (TD 8850) 2, 265 26 CFR 1.6046A–1, added; return requirement for U.S. persons acquir- ing or disposing of an interest in a foreign partnership (TD 8851) 2, 275 26 CFR 301.6103(j)(5)–1T, added; disclosure of return information; Census of Agriculture (TD 8854) 3, 306 26 CFR 301.6104(d)–1, removed; 301.6104(d)–2, redesignated as 301.6104(d)–0, revised; 301.6104(d)–3, redesignated as 301.6104(d)–1, amended; 301.6104(d)–4, redesignated as 301.6104(d)–2, amended; 301.6104(d)–5, redesignated as 301.6104(d)–3, amended; 602.101(b), amended; private foun- dation disclosure rules (TD 8861) 5, 442 26 CFR 301.6111–2T, added; corpo- rate tax shelter registration (TD 8876) 11, 753 26 CFR 301.6112–1T, amended; requirements to maintain list of investors in potentially abusive tax shelters (TD 8875) 11, 761 Removal costs, capital expenditures (RR 7) 9, 712 Reorganizations: Divisive mergers, definition (RR 5) 5, 436 Solely for voting stock requirement (Notice 1) 2, 288 Research credit, controlled group (REG–105606–99) 4, 421 S corporations: Passthrough items (TD 8852) 2, 253; correction (Ann 18) 13,846; correc- tion (Ann 32) 15,878 Subsidiaries (TD 8869) 6, 498; correc- tion (Ann 36) 16,947 Separate shares rules (TD 8849) 2, 245; correction (Ann 28) 15,876 Short-term Treasury bills (Ann 14) 11, 772 Sources of income, compensation for labor or services (REG–208254–90) 6, 577 Tax conventions: New treaties with Estonia, Latvia, Lithuania, Venezuela; Publication 515 changes (Ann 11) 10, 739 2000–18 I.R.B.ixMay 1, 2000 INCOME TAX—cont.INCOME TAX—cont.INCOME TAX—cont. Treaties with Austria, Ireland, South Africa; Publication 515 changes (Ann 11) 10, 739 United Kingdom; repeal of advance corporation tax (RP 13) 6, 515 Tax liens, determination of property or rights to property (CD 2067) 15, 863 Tax shelters: Confidential corporate, registration (TD 8876) 11, 753; (REG–110311–98) 11,753 Disclosure statements (TD 8877) 11, 747; (REG–103735–00) 11, 770 Listed transactions (Notice 15) 12, 826 Office of Tax Shelter Analysis (Ann 12) 12,835 Potentially abusive, list of investors (TD 8875) 11, 761; (REG–103736–00) 11, 768; correc- tion (Ann 44) 17,958 Technical advice to district directors and chiefs, appeals office, from Associate Chief Counsel (RP 2) 1, 73 Valuation tables (Ann 25) 14, 855 Variable annuity contracts, closing agree- ments (Notice 9) 5, 449 Withholdings: Date deemed paid (CD 2066) 15, 867 Qualified intermediary withholding agreements (RP 12) 4, 387 U.S. source income payments to for- eign persons, delay of effective date (TD 8856) 3, 298; correction (Ann 31) 15, 877 May 1, 2000x2000–18 I.R.B. 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